EIN: 390980974
UEI: GSA_MIGRATION
Audited by: PLANTE & MORAN, PLLC
Oversight agency: 84 [Department of Education]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on October 8, 2020. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by April 8, 2021 (1970 days ago).
What is a management decision? →CFDA Number, Federal Agency, and Program Name Student Financial Assistance Cluster (SEOG 84.007, FWS 84.033, Pell 84.063, and Federal Direct Loans 84.268) Federal Award Identification Number and Year N/A Pass through Entity N/A Finding Type Significant deficiency Repeat Finding Yes 2019 003 Criteria A college must identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risks in each relevant area of your operations, including employee training and management; information systems, including network and software design, as well as information processing, storage, transmission and disposal; and detecting, preventing, and responding to attacks, intrusions, or other systems failures (16 CFR Section 314.4(b)). The Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards to establish and maintain effective internal control designed to reasonably ensure compliance with federal laws, statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures to ensure compliance with the Gramm Leach Bliley Act (GLBA). Condition The College did not document a GLBA focused risk assessment during fiscal year 2020. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context The College did not document a GLBA focused risk assessment during fiscal year 2020. Without documentation of a risk assessment, the College is at risk of noncompliance with the GLBA. Cause and Effect Assessments performed by the College did not address all required risks, as mandated by GLBA. As a result, there is a risk that college systems and information could be vulnerable to attacks or intrusions, and these attacks may not be detected in a timely manner. Recommendation We recommend the College implement and document procedures to ensure compliance with the Gramm Leach Bliley Act. Views of Responsible Officials and Corrective Action Plan Management agrees and began implementing procedures, but upon the announcement of the College closing, efforts were ceased on fully implementing all aspects of GLBA compliance. Since the College is ceasing operations in August 2020, there will be no further corrective action.
Show full finding ▾Hide full finding ▴CFDA Number, Federal Agency, and Program Name Student Financial Assistance Cluster (SEOG 84.007, FWS 84.033, Pell 84.063, and Federal Direct Loans 84.268) Federal Award Identification Number and Year N/A Pass through Entity N/A Finding Type Significant deficiency Repeat Finding Yes 2019 003 Criteria A college must identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risks in each relevant area of your operations, including employee training and management; information systems, including network and software design, as well as information processing, storage, transmission and disposal; and detecting, preventing, and responding to attacks, intrusions, or other systems failures (16 CFR Section 314.4(b)). The Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards to establish and maintain effective internal control designed to reasonably ensure compliance with federal laws, statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures to ensure compliance with the Gramm Leach Bliley Act (GLBA). Condition The College did not document a GLBA focused risk assessment during fiscal year 2020. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context The College did not document a GLBA focused risk assessment during fiscal year 2020. Without documentation of a risk assessment, the College is at risk of noncompliance with the GLBA. Cause and Effect Assessments performed by the College did not address all required risks, as mandated by GLBA. As a result, there is a risk that college systems and information could be vulnerable to attacks or intrusions, and these attacks may not be detected in a timely manner. Recommendation We recommend the College implement and document procedures to ensure compliance with the Gramm Leach Bliley Act. Views of Responsible Officials and Corrective Action Plan Management agrees and began implementing procedures, but upon the announcement of the College closing, efforts were ceased on fully implementing all aspects of GLBA compliance. Since the College is ceasing operations in August 2020, there will be no further corrective action.
Finding Number: 2020-004 Condition: The College did not document a GLBA-focused risk assessment during fiscal year 2020. Planned Corrective Action: The College is ceasing operations in August 2020, there will be no further corrective action. Contact person responsible for corrective action: The College is ceasing operations in August 2020, there will be no further corrective action. Anticipated Completion Date: 8/29/2020
2019-003
FAC accepted this audit on March 29, 2020 — management decision was due September 29, 2020.
CFDA Number, Federal Agency, and Program Name - Student Financial Assistance Cluster (SEOG - 84.007, FWS - 84.033, Pell - 84.063, and Federal Direct Loans - 84.268) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - A college must identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risks in each relevant area of your operations, including employee training and management; information systems, including network and software design, as well as information processing, storage, transmission and disposal; and detecting, preventing, and responding to attacks, intrusions, or other systems failures. (16 CFR Section 314.4(b)). Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards to establish and maintain effective internal control designed to reasonably ensure compliance with federal laws, statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures to ensure compliance with the Gramm-Leach-Bliley Act (GLBA). Condition - The College did not document a GLBA-focused risk assessment during fiscal year 2019. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - N/A Context - The College did not document a GLBA-focused risk assessment during fiscal year 2019. Without documentation of a risk assessment, the College is at risk of noncompliance with the GLBA. Cause and Effect - Assessments performed by the College did not address all required risks as mandated by GLBA. As a result, there is a risk that college systems and information could be vulnerable to attacks or intrusions, and these attacks may not be detected in a timely manner. Recommendation - We recommend the College implement and document procedures to ensure compliance with the Gramm-Leach-Bliley Act. Views of Responsible Officials and Corrective Action Plan - Management agrees and has begun to implement and document procedures to ensure compliance with the Gramm-Leach-Bliley Act.
Show full finding ▾Hide full finding ▴CFDA Number, Federal Agency, and Program Name - Student Financial Assistance Cluster (SEOG - 84.007, FWS - 84.033, Pell - 84.063, and Federal Direct Loans - 84.268) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - A college must identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risks in each relevant area of your operations, including employee training and management; information systems, including network and software design, as well as information processing, storage, transmission and disposal; and detecting, preventing, and responding to attacks, intrusions, or other systems failures. (16 CFR Section 314.4(b)). Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards to establish and maintain effective internal control designed to reasonably ensure compliance with federal laws, statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures to ensure compliance with the Gramm-Leach-Bliley Act (GLBA). Condition - The College did not document a GLBA-focused risk assessment during fiscal year 2019. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - N/A Context - The College did not document a GLBA-focused risk assessment during fiscal year 2019. Without documentation of a risk assessment, the College is at risk of noncompliance with the GLBA. Cause and Effect - Assessments performed by the College did not address all required risks as mandated by GLBA. As a result, there is a risk that college systems and information could be vulnerable to attacks or intrusions, and these attacks may not be detected in a timely manner. Recommendation - We recommend the College implement and document procedures to ensure compliance with the Gramm-Leach-Bliley Act. Views of Responsible Officials and Corrective Action Plan - Management agrees and has begun to implement and document procedures to ensure compliance with the Gramm-Leach-Bliley Act.
Finding Number: 2019-003 Condition: The College did not document a GLBA-focused risk assessment during fiscal year 2019. Planned Corrective Action: This corrective action plan focuses on the development and execution of a risk assessment process to ensure compliance with GLBA. Using the Federal Financial Institutions Examination Council (FFIEC) Cybersecurity Assessment Tool, we will determine any risks as well as our cybersecurity maturity. Use the results of the assessment to update our current security plan to ensure protection of customer information. Contact person responsible for corrective action: Patty Huettl, Interim CFO Anticipated Completion Date: 5/31/2020 and ongoing
FAC accepted this audit on January 27, 2019 — management decision was due July 27, 2019.
FAC accepted this audit on February 26, 2018 — management decision was due August 26, 2018.
GSA_MIGRATION
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2016-004
FAC accepted this audit on January 11, 2017 — management decision was due July 11, 2017.
GSA_MIGRATION
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2015-003
GSA_MIGRATION
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GSA_MIGRATION
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